Lieber Institute essays examine the legal status of non-state hackers and the unresolved gray zones of international humanitarian law in digital conflict
WASHINGTON, D.C., August 2025 — Law & Forensics LLC congratulates expert consultant Gary Corn on the publication of a two-part analysis examining the law of armed conflict implications of non-state cyber operations during the June 2025 Israel-Iran conflict, published by the Lieber Institute for Law & Land Warfare at West Point. The series, titled "Non-State Cyber Actors in the 12-Day War — The Gray Zone of LOAC," appeared in two installments: Part I on July 25, 2025, and Part II on August 5, 2025. (Source) (Source)
The essays analyze the activities of approximately 170 hacking groups that targeted Israel and 55 that targeted Iran during the 12-day escalation beginning June 13, 2025, conducting operations ranging from espionage to destructive attacks on financial infrastructure. Corn focuses in particular on the group Predatory Sparrow, which claimed responsibility for disrupting Bank Sepah and stealing $90 million from cryptocurrency exchange Nobitex, examining how international law should classify and regulate such actors and their operations. (Source)
Part I addresses the fundamental question of how law of armed conflict rules for classifying non-state cyber actors — as civilians participating directly in hostilities, unprivileged belligerents, or protected persons — apply to groups like Predatory Sparrow operating in geographic and legal gray zones. Part II examines the consequences of that classification for detention, prosecution, and the lawfulness of targeting, highlighting three unresolved doctrinal debates: whether non-destructive cyber operations constitute prohibited "attacks" under IHL, whether digital data qualifies as a targetable object, and how existing law accommodates remote cyber operations. (Source)
The Lieber Institute's Articles of War blog, published at West Point's United States Military Academy, is among the most widely read platforms for current legal analysis of armed conflict law, military operations, and the law of war.
Corn's dual-part series adds to a body of timely legal scholarship including his April 2026 research paper "Cognitive Warfare: Generative AI, False Realities, and International Humanitarian Law," published in the Joint PIJIP/TLS Research Paper Series at American University Washington College of Law, which examines how generative AI deepfakes and automated information operations have outpaced existing IHL regulatory frameworks. (Source)
" The 12-Day War was a live-fire test of how international humanitarian law handles the explosion of non-state cyber actors in modern armed conflict — and the law came up short in important ways," said Gary Corn. "Resolving these gray zones is urgent, not academic, because the next conflict will look much the same."
" Gary's ability to analyze fast-moving conflicts through the lens of operational law — grounded in his years advising U.S. Cyber Command — is exactly the expertise clients need when cyber operations intersect with legal and insurance liability," said Daniel Garrie, Co-Founder of Law & Forensics.
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